The Securities and Exchange Commission (SEC) adopted a series of rule and form amendments on Sept. 27, 2024, concerning access to and management of accounts on its Electronic Data Gathering, Analysis, and Retrieval system (EDGAR). The amendments – designed to enhance the security of EDGAR, improve the ability of filers to manage their EDGAR accounts, and modernize connections to EDGAR – are collectively referred to as EDGAR Next.

EDGAR Next will change how electronic filers and their representatives interface with EDGAR. Currently, the SEC assigns each electronic filer a set of access codes. Any individual in possession of a filer’s access codes may access the filer’s EDGAR account, view and make changes to the information maintained therein, and transmit filings and correspondence to the SEC on the filer’s behalf. EDGAR Next will retire the majority of these codes and require that filers authorize specific individuals to perform these functions. Individuals seeking to access a filer’s account will be required complete a multifactor authentication of their identity.

To permit a streamlined application process for new and prospective electronic filers, the SEC has adopted an amended version of Form ID, the successful submission of which will enroll the applicant automatically in EDGAR Next.

Effective and Compliance Dates

These are important dates to keep in mind.

• March 24, 2025: The EDGAR Next Filer Management dashboard goes live, allowing existing filers to begin enrollment in EDGAR Next. New filers become required to apply for EDGAR access on the amended version of Form ID. Successful new applicants are automatically enrolled in EDGAR Next. Legacy filing processes remain available to enrolled and unenrolled filers through Sept. 12, 2025.
• Sept. 15, 2025: The initial EDGAR Next enrollment window ends and compliance with EDGAR Next security protocols becomes required of all filers. Existing filers who have not enrolled in EDGAR Next by this time are not able to take actions in EDGAR other than enroll. Enrollment continues to be permitted for a three-month grace period.
• Dec. 19, 2025: The grace period for EDGAR Next enrollment ends. Existing filers who have not enrolled become required to reapply for EDGAR access on an amended Form ID.

EDGAR Next Roles and Permissions

EDGAR Next requires each electronic filer to authorize and maintain at least two individuals (or one, in the case of a filer that is an individual or single-member company) as account administrators. Account administrators manage the filer’s EDGAR account, make submissions on behalf of the filer, serve as points of contact for SEC staff, and authorize and de-authorize other account administrators, users, delegated entities and technical administrators.

A filer may empower up to 20 account administrators. All account administrators are co-equal, possessing the same authority and responsibility to manage the filer’s EDGAR account. Actions that are required to be performed by account administrators can be performed by any account administrator individually and do not require joint action.

Filers – through their account administrators – optionally may authorize:

1. Users: Individuals permitted to view basic information about the filer and transmit filings on behalf of the filer, but lacking administrative privileges to make changes to the filer’s account.
2. Delegated Entities: Entities, authorized representatives of which are permitted to view basic information about the filer and transmit filings on behalf of the filer but lack administrative privileges to make changes to the filer’s account. A delegated entity must possess an EDGAR account. A delegated entity’s account administrators are considered delegated account administrators in respect of a delegating filer’s EDGAR account; delegated account administrators may authorize delegated users in respect of a delegating filer’s EDGAR account.
3. Technical Administrators: Individuals permissioned to manage the technical aspects of a filer’s connection to EDGAR application programming interfaces (APIs), including the issuance, sharing and deactivation of API tokens. Connection to EDGAR APIs is optional, however, filers electing to connect to APIs must authorize and maintain at least two technical administrators.

   It is expected that many filers will leverage API connections maintained by filing agents; such filers will not be required to maintain their own technical administrators. Filers should contact their filing agents for information regarding whether and how such agents anticipate leveraging API connections.

Accessing EDGAR and the EDGAR Next Dashboard

All account administrators, users, and technical administrators will be required to complete a multifactor authentication when accessing the EDGAR Filing and OnlineForms websites, as well as when interacting with the EDGAR Next Filer Management Dashboard. The individual account credentials used for this purpose must be obtained through login.gov, the U.S. General Services Administration’s secure sign-in service.

Once a year (at the quarter end of their choosing), filers will reconfirm their account administrators, users, delegated entities and technical administrators through a check-the-box election on the EDGAR Next Filer Management dashboard. Account administrators separately may authorize or de-authorize account administrators, users, delegated entities and technical administrators at any point throughout the year.

Enrolling in EDGAR Next

Existing filers that maintain current EDGAR access codes will enroll in EDGAR Next through the EDGAR Next Filer Management dashboard. Existing filers will not be required to submit an amended Form ID application or present supplemental documentation to SEC staff; they need only provide the names and contact information of their initial account administrators. Filers must provide the email address associated with each initial account administrator’s login.gov account.

Bulk enrollment of existing EDGAR accounts will be permitted to further streamline the enrollment process. The EDGAR Business Office anticipates that the majority of enrollment requests will be processed in minutes.

Prospective filers seeking to obtain EDGAR access for the first time, as well as existing filers that have lost access to EDGAR or failed to enroll in EDGAR Next by Dec. 19, 2025, will be required to submit an amended Form ID application. The amended Form ID includes a section allowing applicants to identify account administrators. If an applicant wishes to appoint an account administrator not employed by the applicant, the applicant must present a notarized power of attorney indicating that the prospective account administrator is duly authorized to manage the applicant’s EDGAR account. The EDGAR Business Office anticipates that amended Form ID applications will be processed on the same timetable as current Form ID applications.

Account Management and Filing Considerations for Entities

The SEC recommends that all filing entities, including single-member entities, authorize at least two account administrators. Filing entities are permitted, but not required, to designate employees as account administrators.

Currently, many entities liaise with law firms and third-party filing agents to transmit filings and correspondence to the SEC. EDGAR Next will continue to permit this. Law firms and filing agents will offer varying service models. Two anticipated common models are:

• Full-Service Model: Some law firms and filing agents will offer end-to-end service, preparing and transmitting filings and correspondence to the SEC on behalf of clients. Firms and agents offering full-service models will generally act as delegated entities in respect of client EDGAR accounts; some may permit their representatives to act as account administrators or users of client accounts.
• Self-Service Model: Some law firms and filing agents will offer more limited, self-service models. Firms and agents offering self-service models may provide clients with access to filing software and/or otherwise support clients in preparing and transmitting filings and correspondence via EDGAR, but generally will not require that clients delegate to them.

Account Management and Filing Considerations for Individuals

The SEC recommends that all individual filers authorize at least two account administrators. Individual filers are permitted, but not required, to act as their own account administrators.

Currently, many individual filers authorize trusted third parties (such as law firms, filing agents or related registrants) to access their EDGAR accounts and make SEC filings on their behalf. EDGAR Next will continue to permit this. A non-exhaustive list of options for individual account management are:

• Self-Administration: Some individual filers will act as their own account administrators, authorizing trusted third parties as users and delegating to law firms, filing agents or registrants, empowering such users and delegated entities to make filings on their behalf while retaining personal control over the maintenance of their EDGAR account. 
• Close Administration: Some individual filers will authorize a close group of trusted third parties to act as account administrators, permitting such account administrators to maintain their EDGAR account and authorize users and delegated entities to make filings on their behalf.
• Decentralized Administration: Some individual filers will authorize a larger group of account administrators. For example, a Section 16 insider who sits on the board of several public companies may authorize one or more account administrators at each company, permitting each account administrator to authorize users and delegate to preferred filing agents.

Preparing for What’s “Next”

To get a jump on preparing for enrollment in EDGAR Next, existing filers should:

1. Locate and validate their current EDGAR access codes (i.e., CCC, password and passphrase)
2. Identify the individual responsible for enrolling them in EDGAR Next
3. Determine the individuals and entities that will act as account administrators, users, delegated entities and technical administrators (if applicable)
4. Ensure that all desired account administrators, users, and technical administrators maintain login.gov credentials
5. Connect with law firms and filing agents (as applicable) regarding their service offerings

Takeaways

EDGAR Next offers a more secure, modernized connection to EDGAR, and its Filer Management dashboard provides a more intuitive, user-friendly interface for interaction with EDGAR. Filers should plan to devote time and attention to preparing for, enrolling in and becoming comfortable navigating the new system.